### Facts:
This case concerns two separate charges against ABC, accused of raping and committing acts of lasciviousness against his minor daughter, referred to as AAA. The charges were filed for incidents that took place in Quezon City, Philippines, between January and May 2011. ABC pleaded “not guilty” to both charges. During the trial, evidence presented by the prosecution included the testimony of AAA, who detailed how she was sexually abused by ABC, her father, on multiple occasions. Additionally, AAA’s brother, DDD, testified, witnessing one of the incidents. Following AAA’s revelation to her aunt, a complaint was filed, leading to ABC’s arrest and medical examination of AAA, revealing evidence of sexual abuse.
The Regional Trial Court (RTC) convicted ABC of rape in Criminal Case No. R-QZN-14-07929-CR, sentencing him to reclusion perpetua and ordering him to pay damages. However, in Criminal Case No. R-QZN-14-07928-CR for another count of rape, the court found the evidence insufficient for a rape conviction but convicted ABC of acts of lasciviousness, with a lighter sentence and damages awarded.
ABC appealed to the Court of Appeals (CA), which affirmed the RTC’s decision in Criminal Case No. R-QZN-14-07929-CR for rape but modified the judgment in Criminal Case No. R-QZN-14-07928-CR, labeling the offense as Acts of Lasciviousness under the Revised Penal Code in relation to Section 5(b) of R.A. No. 7610, adjusting the sentence and damages accordingly.
ABC then filed an appeal to the Supreme Court, contesting his convictions on the grounds of the prosecution’s failure to prove the crimes and alleged inconsistencies in testimonies.
### Issues:
1. Whether the prosecution successfully established ABC’s guilt for the crime of rape (Criminal Case No. R-QZN-14-07929-CR) and acts of lasciviousness (Criminal Case No. R-QZN-14-07928-CR) beyond reasonable doubt.
2. Whether the testimonies of the prosecution witnesses were credible, consistent, and sufficient to support a conviction.
3. The proper penalty and damages for the crimes committed, considering the modifying circumstances and relevant laws.
### Court’s Decision:
The Supreme Court dismissed ABC’s appeal, upholding the CA’s decision with modification regarding damages. The Court found no merit in ABC’s contentions, reaffirming the credibility of the prosecution witnesses, especially AAA, and the sufficiency of evidence demonstrating ABC’s guilt beyond reasonable doubt for both charges.
For Criminal Case No. R-QZN-14-07929-CR, the conviction for rape was maintained, with the penalty of reclusion perpetua upheld. In Criminal Case No. R-QZN-14-07928-CR, the Court agreed with the CA’s reclassification of the offense to Acts of Lasciviousness in relation to R.A. No. 7610 and adjusted the sentence and damages. The Court emphasized the vulnerability of child victims and the weight given to their testimonies.
### Doctrine:
This decision reiterates the principle that the testimony of a child victim of sexual abuse is given full weight and credit. It underscores the court’s approach in cases involving vulnerable victims, such as children, where their candid, straightforward, and categorical narration of events is pivotal in ascertaining the truth.
### Class Notes:
– The credibility of witnesses, especially in rape and sexual abuse cases involving minors, is crucial and is generally given significant weight by the courts.
– The legal definitions and penalties for rape and acts of lasciviousness are clearly outlined in the Revised Penal Code and R.A. No. 7610.
– The importance of establishing beyond reasonable doubt the guilt of the accused in criminal cases.
– The significance of aggravating circumstances, such as the relationship between the perpetrator and the victim, in determining the penalty.
### Historical Background:
This case contributes to the jurisprudence protecting children against sexual abuse and underscores the severity with which the Philippine legal system treats crimes involving sexual abuse of minors, particularly by parents or guardians. It highlights legislative and judicial efforts to address and prevent such abuses within the family setting, reflecting societal values and the state’s responsibility in safeguarding children’s rights and welfare.
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